For many users, yes. I know many people with complicated phones that don't even know what a folder or file is. How do you expect they find their music files then find where to drag them to?
Now, that is surely not Apple's problem. All Palm and other device manufacturers have to do (as RIM does) is to create their own app or license an exiting app to sync with iTunes library file. That's what device manufacturers have to do if they want to give their users the option to sync with iTunes. Any direct hack into iTunes to safe cost without proper permission from Apple is illegal.